- Extension of certain proposed RMD regulationsThe IRS issued Announcement 2026-7, extending the effective date of certain provisions in proposed required minimum distribution regulations.
- Proposed Regulations Related to Required StatementsThe DOL issued proposed regulations implementing requirements related to the electronic delivery of certain notices and disclosures.
- DOL National Enforcement Projects for Employee Benefit PlansThe DOL announced an overhaul of its national enforcement projects for 2026.
- Puerto Rico 2026 LimitsThe Puerto Rico Department of Treasury announced the 2026 limits for retirement plans dually or solely qualified in Puerto Rico.
- Disaster ReliefThe IRS and PBGC have issued disaster relief in response to severe storms and flooding in Louisiana and Montana.
The Internal Revenue Service (IRS) issued Announcement 2026-7 (the Announcement), which extends the effective date of certain provisions in proposed required minimum distribution (RMD) regulations, previously published on July 19, 2024. The effective date of certain provisions will apply for the distribution calendar year that begins no earlier than 6 months after the date that final regulations are issued.
Background
On July 19, 2024, the IRS jointly issued final and proposed RMD regulations. The updates reflect recent IRS guidance as well as congressional laws, including changes introduced by the Setting Every Community Up for Retirement Enhancement Act of 2019 and the SECURE 2.0 Act of 2022. These updates impact defined benefit retirement plans, defined contribution retirement plans (such as money purchase, 401(k), profit sharing, 403(b), and eligible governmental 457(b) retirement plans), and individual retirement accounts and annuities (IRA).
Deadline Extended
The following provisions in the proposed RMD regulations, previously set to become effective on January 1, 2025, will now apply no earlier than 6 months after the date that final regulations are issued:
- The eligibility status of a designated beneficiary of a surviving spouse if the spouse dies
- Changes to certain provisions related to RMDs from defined contribution (DC) plans, including
- The determination of RMDs related to annuity contracts
- The provisions stating that certain corrective distributions and distributions from designated Roth accounts are not taken into account for purposes of satisfying RMD requirements
- Certain details around allowing a surviving spouse to elect to use the Uniform Lifetime table in a DC plan
- Situations when a divorce or separation instrument may be used in lieu of a qualified domestic relations order if a divorce occurs after purchasing certain qualifying longevity annuity contracts
Next Steps in 2026
As outlined in the Announcement, “for periods before the applicability date of these amendments, taxpayers must apply a reasonable, good-faith interpretation of the statutory provisions underlying the amendments”.
The Department of Labor (DOL) issued proposed regulations implementing requirements related to the electronic delivery of certain notices and disclosures, mandated under the SECURE 2.0 Act of 2022 (SECURE 2.0). The provisions are effective for plan years beginning after December 31, 2025.
Background
Section 338 of the SECURE 2.0 Act added ERISA §105(a)(2)(E), which requires that defined contribution plans provide at least one annual paper statement to participants, and defined benefit plans provide a paper statement at least once every three years (excluding one participant plans). In connection with this additional requirement, the DOL was also directed to make certain changes to its electronic delivery rules.
The two existing safe harbors for electronic delivery of required notices and disclosures are:
- The 2002 safe harbor: Documents can be sent electronically to participants who are wired at work (employer’s electronic information system is an integral part of their job duties), or who have affirmatively consented to electronic delivery.
- The 2020 safe harbor: An electronic notice of internet availability can be sent if a participant receives an initial notice informing them of that the documents will be provided electronically, the email address the notification will be sent to, their right to request paper documents without cost, and how they may make that election.
Proposed Regulations
Newly eligible participants and beneficiaries after December 31, 2025, must receive a one-time initial paper notice with the required information before required notices and statements can be sent electronically.
For all other participants and beneficiaries, the annual paper statement is still required; however, there are two exceptions that allow the annual statement to be sent electronically to participants:
- Participant must be wired at work (and, if newly eligible after December 31, 2025, have received the one-time initial paper notice), or
- Participant has affirmatively consented to electronic delivery.
Next Steps and Comments
The DOL stated that until they issue a final rule or other applicable guidance, they will not take enforcement action against plan administrators that comply in good faith with a reasonable interpretation of the provisions.
Comments on the proposed regulations may be submitted to the DOL on or before April 27, 2026, and must be identified by RIN 1210-AC27. They can be submitted using either of the following addresses.
- Federal eRulemaking Portal:
https://www.regulations.gov . Follow the instructions for submitting comments. - Mail: Office of Regulations and Interpretations, Employee Benefits Security Administration, Room N-5655, U.S. Department of Labor, 200 Constitution Avenue NW, Washington, DC 20210, Attention: Requirement to Provide Paper Statements in Certain Cases— Amendments to Electronic Disclosure Safe Harbors, RIN 1210-AC27.
The Department of Labor’s Employee Benefits Security Administration (EBSA) recently announced an overhaul of its national enforcement projects for 2026. The enforcement projects, as outlined in the EBSA’s internal Enforcement Manual, highlight where EBSA will focus its enforcement resources. Under the updated enforcement projects, investigators will prioritize cases related to:
- Cybersecurity
- Barriers to mental health and substance use disorder benefits
- Protecting benefit distributions
- Retirement asset management
- Surprise billing
- Criminal abuse of contributory benefit plans
EBSA removed Employee Stock Ownership Plans from the national enforcement project list and will reduce its focus on missing participants following the establishment of the Retirement Savings Lost and Found database.
The Puerto Rico Department of Treasury announced the 2026 limits for retirement plan sponsors of dually qualified plans and plans qualified solely in Puerto Rico.
| Description | 2025 | 2026 |
|---|---|---|
| Compensation | $350,000 | $360,000 |
| Defined Contribution Annual Contribution Limit | $70,000 | $72,000 |
| Defined Benefit Annual Benefit Limit | $280,000 | $290,000 |
| Highly Compensated Employee | $160,000 | $160,000 |
| Pretax Elective Deferral – Dual Qualified | $20,000 | $22,500 |
| Pretax Elective Deferral – Solely Qualified | $15,000 | $15,000 |
| Catch-up – Dual and Solely Qualified (plan not sponsored by federal government and at least age 50 by plan year end) | $1,500 | $1,500 |
| Catch-up (Only retirement plans sponsored by U.S. federal government and employees over age 50) | $7,500 | $8,000 |
| After-Tax Voluntary – Solely Qualified | 10% of the participant’s maximum recognizable compensation for all years of participation in the retirement plan | |
| Periodic payments that are not subject to 10% withholding in Puerto Rico | Retirees under age 60, the first $31,000. For those age 60 or older as of December 31, the first $35,000. | |
In response to severe storms and other disaster events, the Internal Revenue Service (IRS) and Pension Benefit Guaranty Corporation (PBGC) extended certain deadlines for individuals and businesses impacted by such events.
Background
Individuals who reside or have a business in any of the following areas may be eligible for certain deadline relief:
| State | Covered Areas | Certain Deadlines On & After | Certain Deadlines On & Before/Extended Deadline |
|---|---|---|---|
| Louisiana | State of Louisiana | January 22, 2026 | March 31, 2026 |
| Montana | Blackfeet Indian Reservation, Lincoln, and Sanders counties | December 10, 2025 | May 1, 2026 |
Background
Below is a partial list of retirement-impact tax filing and payment deadlines that may be extended:
- Retirement plan loan repayments may be temporarily paused under Internal Revenue Code section 72(p)(2)
- Required minimum distributions under Internal Revenue Code section 401(a)(9)
- The 10% additional income tax continues to not apply even if the following is missed during the relief period:
- Substantially equal payments made over the participant’s life or joint lives of the participant and designated beneficiary
- Deadline for using a distribution from an IRA for a first-time home purchase by the close of the 120th day after the distribution is received
- Prior tax year contribution deadlines for retirement plans
- Indirect rollover distribution deadlines
- 60-day rollovers
- Rollover of qualified loan offsets
- Refunds as a result of
- Excess deferrals
- ADP/ACP non-discrimination testing
- Eligible automatic contribution arrangement (EACA) withdrawals
- Excess IRA contributions
- Deadline for recontributing qualified reservist distributions
- Form 5500 and Form 8955-SSA filing
- Form 5948 for IRAs
- PBGC premium payments
- PBGC deadlines that are based on the Form 5500 deadline
- Single Employer Plan Termination Forms 500 and 501
Additional Resources
For any questions related to IRS deadlines and other disaster-related issues, the IRS has a toll-free number at